Our whistleblowing policy allows anyone who wants to report a suspected breach to do so, such as employees or former employees, independent contractors, shareholders or suppliers.
We encourage anyone to report any suspected wrongdoing or irregularity to us, in good faith and without delay.
For a translation of this policy in Spanish, click here:
Julie Sloan
Director, Internal Audit and Whistleblowing Officer | Skyscanner
“At Skyscanner, we are committed to proper business conduct in accordance with our values and business principles, both of which require an ethical and transparent way of conducting business and high standards of honesty and integrity from those working for us.”
What can be reported?
Whistleblowing is speaking up about conduct that involves:
- criminal offences (this may include, for example, types of financial impropriety such as fraud or bribery, or very serious administrative or accounting offences affecting tax, auditing or social security payments);
- significant failure to comply with an obligation set out in law;
- miscarriages of justice;
- endangering of someone’s health and safety;
- damage to the environment;
- material breach of our internal policies or procedures (including our business principles);
- damage to the environment;
- conduct likely to damage our reputation or financial well-being;
- unauthorised disclosure of our confidential information or trade secrets;
- irregularities in governance or serious concerns around the functioning of Skyscanner’s Executive team, Trip.com or its subsidiaries; and/or
- the covering up of wrongdoing in the above categories.
A whistleblower is a person who raises a genuine concern relating to wrongdoing.
Whistleblowing doesn’t generally include personal work-related grievances (i.e. something that impacts someone personally). These should be reported directly to the Skyscanner People team.
Whistleblowing doesn’t include traveller/user complaints about use of Skyscanner’s website/app, which can instead be sent to us via our Help Form:
Whistleblowing procedure
We ask that you promptly report any suspected wrongdoing that falls under this policy using the appropriate channel in the Contact Details section below.
To assist us in our response to, or the investigation of, a report you should include as much information as possible in sufficient detail – such as the detail of the suspected wrongdoing, the person(s) involved, any witnesses and the location of any other information that would assist us in understanding and looking into the matter. We will have difficulties investigating reports that do not provide sufficient detail.
We will ensure all disclosures reported via our channels are treated in a confidential, fair and unbiased manner and the anonymity of a reporter is preserved at all times (where anonymity is sought) as well as maintaining the confidentiality of the investigation. Whistleblowing is centralised within the Skyscanner Legal team to maintain independence, confidentiality and anonymity. Depending on the nature of the disclosure, selected individuals within other functions of Skyscanner may also need to be added to the investigating team – always under strict adherence to confidentiality.
In most cases, we will endeavour to complete our investigation within three months of receiving your disclosure. However, if the issues requiring investigation are sufficiently complex, the investigation may take up to six months.
In Spain (where it is legally required), we have set up the ability to make anonymous reports – details of the channel can be found in the Contact Details section below. The anonymity and confidentiality of those using this channel will always be preserved, and all colleagues who become aware of any disclosure will do the same.
Criminal allegations
If the facts discovered in the investigation indicate a criminal offence may have been committed, we will need to pass the matter over to the relevant authorities without undue delay. We will not usually wait for the outcome of any authority’s investigation or prosecution before deciding what action, if any, to take. Where you are unable or have been advised not to attend a meeting with us as part of our investigation or say anything about a pending criminal matter, we may have to take a decision based on the available evidence.
If you are not satisfied
While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy, you can help us to achieve this. In Spain as required by law, if you are not happy with the way in which your concern has been handled, you can contact the Autoridad Independiente de Protección del Informante, A.A.I.
Protections for whistleblowers
We want everyone to feel able to voice whistleblowing concerns openly under this policy.
Whistleblowers must not suffer any detrimental treatment due to raising a concern. People who report their concerns about conduct which is covered by local whistleblowing laws in good faith are protected against any kind of retaliation.
If you would prefer to raise your concern confidentially, we will make every effort to keep your identity anonymous. All information given to us as part of a whistleblowing complaint will be kept strictly confidential. However, we do not encourage disclosures to be made anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible.
Responsibilities under this policy
The Skyscanner Board has overall responsibility for this policy. However, the Whistleblowing Officer has day-to-day operational responsibility and must ensure that all managers and other staff deal with concerns or investigations appropriately.
The Whistleblowing Officer, our Director of Internal Audit, can be contacted to make a whistleblowing complaint as set out in the Contact Details section below.
Contact Details
To raise a report to the Whistleblowing Officer (or if the report involves them, the Chief People Officer), go to:
For matters about our parent company Trip.com or another group company subsidiary, you can raise the report to:
